To amend the Internal Revenue Code of 1986 to provide that distributions from a controlled foreign corporation to a United States shareholder shall be excluded from gross income if at least a portion of the distribution is invested in certain property located in the United States and in the employment of new employees in the United States.

Amends the Internal Revenue Code to exclude from the gross income of shareholders of controlled foreign corporations the amount of any distribution received from such corporation, if the shareholder meets the requirements for reinvestment in U.S. property or the creation of domestic jobs. Provides a formula to determine the maximum amount of such exclusion.